Ruddiman v. Scow Platform

The libelant sues for wharfage of a scow platform along-side his dock walk, at One Hundred and Thirty-Eighth street, Harlem river, from November, 1886, to November, 1887. No lien under the state law can be claimed, as no specification of claim has been filed, and more than a year has elapsed. To admit of a maritime lien, the scow structure must be a “vessel,” within the meaning of the maritime law. I am of opinion that the structure in question, though afloat, is not such a vessel, because it was not designed or used for the purpose of navigation, nor engaged in the uses of commerce, nor in…